The Babcock Code of Conduct is a clear statement of Babcock’s commitment to doing business in the right and proper way.
Babcock has developed its approach to ensure that wherever Babcock is doing business in the world, no matter how challenging the circumstances, all those who act for Babcock are aware of what is expected of them and how Babcock expects to do business. This approach is summarised below.
1. Top level commitment
The cornerstone to Babcock’s ethical approach is its Code of Conduct. Babcock’s Chairman and Chief Executive issued this Code of Conduct to all employees and it continues to be on display at all Babcock facilities. The Code is also part of all new employees’ induction packs. Babcock’s Chief Executive has personally endorsed the Code of Conduct to Babcock’s senior management across the Group and emphasises the importance that he attaches to the Code. Babcock’s Sector Chief Executives in turn take the lead in supporting the Code to their respective Sector teams and employees.
However, Babcock recognises that it is not enough simply to state Babcock’s commitment to an ethical approach. Each Sector and Business Unit is required to have clear, proportionate procedures designed to ensure that the business done by each Sector or done on its behalf is done ethically and honestly. For example, each Babcock business has a gifts and hospitality policy, appropriate to its market, which gives clear and practical guidance to each Babcock employee in respect of corporate entertainment. Further, these procedures inform Babcock employees as how they should ensure that those entities with whom Babcock does business or who represent Babcock’s interests share Babcock’s commitment to ethical compliance. Before doing any business (whether as a customer, a supplier, a joint venture partner or an agent) Babcock requires its businesses to conduct an appropriate level of due diligence on Babcock’s counterparty. Where there are what might be high risk appointments, the procedures require a greater level of scrutiny and more in-depth due diligence. For example, all appointments of agents and all joint ventures must be approved by the Chief Executive. The terms of appointments of any agent or joint venture are required to include appropriate protections to guard against unethical behaviour by the agent or joint venture party. In addition, our Sectors refresh their due diligence on all agents at least every two years.
So that the procedures are properly understood and applied, Babcock recognises that it must ensure that it has given its employees the right training. Babcock requires all its employees with access to the Babcock network to complete an on-line training module. In addition, each Sector has identified those departments in its business where ethical compliance is particularly relevant (for example, bid teams or procurement). In these areas, the Sectors give specific face to face training.
All Babcock employees wherever they work in the world are encouraged to see protecting Babcock’s integrity as their responsibility and have access to a reporting helpline so that they can raise any concerns they may have. All reports to the helpline are reported to an independent third party who then passes the report to a senior executive at Babcock head office for investigation. Callers may remain anonymous if they wish and no one is adversely treated for making a report.
5. Monitoring and review
Babcock requires its Sectors to perform a continuous risk assessment of each of their businesses. Each Sector risk register includes those ethical compliance risks that the Sector may face as well as an assessment as to whether its procedures are adequate to deal with those risks. Twice yearly each Sector presents its risk register to Babcock head office for review. Any issues identified are then appropriately dealt with.
6. Anti-Bribery and Corruption/Ethical Policy
All employees within the Babcock Group are required to comply with the Babcock Anti-Bribery and Corruption/Ethical Policy. This policy can be accessed using the link below